Comment Analysis · Docket FS-2025-0001

FS-2025-0001-338661

Opposes rescissionA1 strongSubstance 15/24Owed an answerPosted September 8, 2026 On Regulations.gov

In short: The comment documents that the Draft EIS fails to analyze specific hunting and recreation impacts in the Wolfpen IRA and relies on a stale, non-existent citation (White et al. 2016) for FY2024 recreation visitation data, violating the rational basis requirements of State Farm and NEPA scientific integrity standards.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
EA analysisEngages the agency's environmental analysis directly.
Analytical gapIdentifies something the analysis fails to address.
EvidenceBacks claims with specific facts, data, or research.
RequestMakes a specific, actionable request of the agency.
AlternativeProposes a different course of action.
LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A1 strong: Must be answered — it names the law.

Owed an answer on Analytical gap, Evidence, Legal.

Standard dismissals it defeats

Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Still open to the agency

Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.

Topics

Wildlife Habitat
- “continuous habitat for forest-interior species”
- “Road construction creates permanent edge habitat”
- “fragmenting the continuous canopy that these species require”
- “invasive species and generalist predators to penetrate the forest interior”
Recreation Tourism Public Use
- “reduces hunting visitation by degrading the qualities visitors seek”
- “solitude, clean water, intact wildlife, backcountry character”
- “recreation economy near Daniel Boone National Forest depends on the roadless condition”
- “anthropogenic noise doubled background sound levels”
Legal Regulatory Framework
- “overturning such a conclusion requires a comparably rigorous administrative basis”
- “Stale-Source Citation for FY2024 Recreation Visitation Statistic”
- “Under Motor Vehicle Manufacturers Association v. State Farm”
- “agency NEPA procedures on scientific integrity and reasonably available materials require accurate sourcing”
Water Quality Quantity
- “clean water”
- “water quality”
- “drinking-water sources”

What it names

National Forests: Daniel Boone National Forest
Law cited: 463 U.S. 29
Works cited: White et al. 2016

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: EvidenceLegal

To the U.S. Forest Service Roadless Rule Docket: As an outdoor enthusiast, I respectfully urge the Department to consider that the 2001 Roadless Area Conservation Rule represents a policy conclusion reached after one of the most extensive administrative processes in Forest Service history — and that overturning such a conclusion requires a comparably rigorous administrative basis, which the proposed rescission has not yet provided. I spent time in the Daniel Boone National Forest when I was growing up and still visit to hike there. Outdoor space like this brings peace. Much peace will be lost if it is destroyed. Regarding the Wolfpen in the Daniel Boone National Forest, Kentucky: Interior Forest Connectivity for Declining Forest-Interior Species — The unfragmented canopy of Wolfpen's Cumberland mixed mesophytic and eastern hemlock-hardwood forests provides continuous habitat for forest-interior species including the eastern whip-poor-will (near threatened) and the green salamander (near threatened), both of which avoid edges and require large, undisturbed forest blocks. The eastern hemlock itself (near threatened globally) forms dense, structurally complex stands in the coves that support specialized invertebrate communities. Road construction creates permanent edge habitat, allowing invasive species and generalist predators to penetrate the forest interior, fragmenting the continuous canopy that these species require for breeding and survival. Road construction in the Wolfpen IRA reduces hunting visitation by degrading the qualities visitors seek — solitude, clean water, intact wildlife, backcountry character. Every lost visitor represents lost spending at local outfitters, guides, lodges, restaurants, and gas stations. The recreation economy near Daniel Boone National Forest depends on the roadless condition, and road construction undermines it directly. The DEIS must analyze how road construction degrades the specific qualities that support hunting in the Wolfpen IRA — solitude, natural soundscape, water quality, wildlife habitat, and backcountry character — and assess the resulting decline in recreational quality and visitation. A generic statement about recreation impacts is insufficient; the analysis must address hunting conditions in this specific area. "Using continental-scale sound models, we found that anthropogenic noise doubled background sound levels in 63% of U.S. protected area units and caused a 10-fold increase in 21% of protected area units. Elevated noise was also found in critical habitats of endangered species, with 14% experiencing a 10-fold increase in sound levels. Noise pollution in protected areas is closely linked with transportation, development, and extractive land use." — Science (journal), 2017 Stale-Source Citation for FY2024 Recreation Visitation Statistic The Draft EIS states that "the 193 million acres administered by the Forest Service received approximately 164 million recreation visits in FY2024" in its discussion of Economic Activity from Recreation in Roadless Areas, but this figure is cited to White et al. 2016 — a publication issued eight years before the reported data year. By definition, a 2016 report cannot be the source of FY2024 visitation data, and independent review confirms that White et al. 2016 is silent on this specific statistic. This is a foundational number underlying the entire recreation-economics discussion used to justify the rescission's benefits, yet it rests on no traceable source. Under Motor Vehicle Manufacturers Association v. State Farm, 463 U.S. 29 (1983), an agency must examine relevant data and articulate a rational basis for its conclusions, and agency NEPA procedures on scientific integrity and reasonably available materials require accurate sourcing. I request that the agency replace this citation with the actual current source, such as the National Visitor Use Monitoring program report, and audit related recreation statistics for the same error. The Secretary should exercise the authority vested in the Department to preserve, not dissolve, the protections the Roadless Area Conservation Rule provides. Best, Valerie Fasimpaur Dayton, Ohio CommentID: RLC-20260908-UKCW9H